Italy’s Revenue Agency has launched an optional tax risk management regime for mid-sized companies with turnovers under EUR 500 million, allowing them to adopt formal systems to monitor and control tax risks. Participation offers exemptions from penalties for disclosed risks, with clear procedures, forms, and documentation requirements established to support compliance.
Italy’s Revenue Agency has introduced a new optional regime on 3 February 2025, allowing companies that do not qualify for the cooperative compliance program to adopt a formal system for detecting, measuring, managing, and controlling tax risk.
The provision, effective 3 February 2026, follows Article 7-bis of Legislative Decree No. 128/2015, as amended by Legislative Decree No. 221/2023.
Companies with a turnover under EUR 500 million for 2026 and 2027, the limit established for the cooperative compliance program, are eligible.
Participation offers significant benefits, including an exemption from administrative and criminal penalties for tax violations arising from risks previously disclosed in a formal tax ruling.
To qualify for the waiver of sanctions, taxpayers must ensure their actions align with the disclosed risks and avoid any fraudulent or simulated conduct. The regime lasts two tax periods and is automatically renewed for another two periods unless expressly revoked.
The Director of the Revenue Agency has approved the official form and instructions for opting into the regime. Companies must submit the form via certified email to the DC Large Taxpayers and International Office (dc.acc.cooperative@pec.agenziaentrate.it), along with the required documentation, including a description of the company’s activities, the approved tax strategy, a tax risk assessment system, process and risk maps, and certification of the control system.
The operational procedures for the regime were originally set out in a decree issued by the Deputy Minister of Economy on 9 July 2025, providing a clear framework for mid-sized businesses to enhance tax compliance while reducing potential exposure to penalties.
